PANAMA INTERVENES WHEN BANCO UNIVERSAL REFUSES TO FREEZE FUNDS

Panama's Superintendent of Banking has taken control of Banco Universal, after the bank arrogantly declined to obey an order, from the Anti-Corruption Prosecutor, freezing accounts estimated to contain over $40m. Not only did the bank refuse to obey the directive, it allowed large transfer of funds to a member of its board of directors, and to others, in clear violation of the governmental order.

Notice of Intervention

Unofficially, reliable sources assert that bank management refused to comply with the freeze order, until and unless former Panamanian Vice resident Felipe Alejandro "Pipo" Virzi Lopez, a corrupt PEP whose family owns a large portion of the bank's stock, was released from prison. Versi has been implicated in one of the country's largest corruption scandals to date. Other owners of the bank have been linked to Panama's largest organized crime group, which includes Panamanians known to be of Middle Eastern origin, and which has influence over every aspect of the local financial structure.

Former Vice President Virzi

  The bank's assets, believed to exceed $300m, have been seized. Banco Universal, which the Anti-Corruption Prosecutor has alleged is guilty of anti-money laundering failures, was the willing recipient of several large cash deposits, made by convicted Colombian Pyramid/Ponzi schemer David Eduardo Helmut Guzmán Murcia, which were said to be the proceeds of narcotics trafficking. Although eyewitnesses reported these deposits to the then-Superintendent of Banking, no investigation was ever conducted, nor any arrests made.


The Superintendent of Banking has taken a giant step towards cleaning up Panama's financial structure, and his actions should be supported. His predecessors were part of the problem but he is now part of the solution. The threshold issue with Panama's reformist government is this: will Panama now formally revoke the charter of a known money laundering bank, with a long and sordid history of criminal behavior, or will it be business as usual with money laundering and terrorist financing in Panama ? Unless a strong enforcement step is taken, Panama's other financial institutions will not fear their government, and continue to move dirty Venezuelan money, Colombian narco-profits, and transfer funds used to support several sanctioned Middle Eastern terrorist organizations. Panama appears to be at a crossroads; will its reform government continue to take off the gloves  ? We sincerely hope that it does so.

PANAMA RULES THAT NORIEGA CANNOT BE TRIED ON ADDITIONAL MURDER CHARGES

General Noriega

A judge in the Republic of Panama has suspended the upcoming murder trial of the imprisoned former dictator, General Manuel Noriega. The General, who served 20 years in a Federal Prison in Miami, and subsequently two years, out of a sentence of seven, in France, for money laundering, is currently incarcerated for a 60-year sentence for the murders of opponents to his regime, when he was president of Panama. This new case involves the murder of a union leader, said to have been murdered by the Army, at Noriega's orders.

When extradited from France, it was solely for the charges which he is serving time for now, and the Doctrine of Specialty, which bars a jurisdiction that extradited an individual from trying him for any crimes other than those which he was extradited for, bars the new murder trial. There have been calls to send Noriega, who is ill, and is 81 years old, to house arrest, for the remainder of what is essentially a life sentence; He has served four years in prison in Panama, and has been hospitalized several times, including a recent visit, after he suffered a fall.

LAWYER FOR PONZI SCHEME WHO PLED OUT RELEASED FROM FEDERAL PRISON

Laughing all the way to the bank

Michael McNerney, the senior equity partner, and co-founder of a downtown Fort Lauderdale law firm, was released from Federal Prison last month, without any publicity or fanfare. McNerney, who as lead attorney for Mutual Benefits Corp. (MBC), the life settlement company that was a billion-dollar Ponzi scheme, kept regulators investigating his client, and unhappy investors, at bay for years, while millions of dollars in illicit profits were drained out of the firm, entered into a plea agreement, and served only a five-year prison term.

In the Statement of Facts, the defendant stipulated that:

(1) He concealed the fact that the true ownership of MBC, and its related entities, was an individual convicted of multiple felonies.

(2) He concealed the true ownership & management structure during on-site visits of state and Federal regulators.

(3) He gave false assurances to investors, directly as well as indirectly.

(4) He failed to disclose to investors that MBC was fraudulently misrepresenting the life expectancies.

(5) He concealed the details of the arrest of the doctor who estimated the life expectancies of the insureds.

(6) He knew about the Ponzi scheme of premium funds.

(7) He allowed MBC to acquire problematic policies with undisclosed risks.

(8) He knew that MBC resold failed policies to new investors.

(9) He gave MBC plausible legal cover for its fraud.

Without McNerney's assistance, MBC would never been able to evade the long arms of regulatory agencies, and law enforcement, for the decade that it was engaged in its Ponzi scheme, disguised as a legitimate investment business While he no longer can practice law in Florida, his short prison term ( the owner of MBC, and the front man "president" both received 20 years) does not serve as an effective deterrent to others who may consider operating their own billion-dollar Ponzi scheme.

CRIME IN THE SPORTS WORLD

Given all the focus this week, on crime in the world of sports, readers may find this website of interest:  The 10 Worst Criminals in the NFL,  which you can access here. 

OUTSIDE COUNSEL CONVICTED IN PONZI SCHEME DENIED A NEW TRIAL FOR MINOR JUROR ERROR

Fort Lauderdale attorney Anthony Livoti, Jr., who served as outside counsel for the Mutual Benefits Corp. (MBC) billion-dollar Ponzi scheme, and who received a ten year sentence, on multiple conspiracy counts of money laundering, and wire & mail fraud, has had his motion for a new trial denied by the US District Judge in the case. MBC, a life settlements company, was owned by Joel Steinger, who is himself serving a 20-year sentence for the massive Ponzi scheme, in which investors sustained a net loss of $800m.

Livoti's attorney had sought a new trial after it was discovered,  more than a year after his conviction, that a juror had mistakenly served in place of his own father, who had the same name as his son. The Court denied his motion, because Livoti failed to show any evidence that demonstrated juror bias or misconduct. His counsel subsequently amended his client's pending Eleventh Circuit Court appeal of his conviction and sentence, to reflect that the denial of the motion for a new trial was also being included in his grounds for appeal.

Attorneys, even when they discharge the role of outside counsel, who conspire with their client, in what is later found to be a criminal enterprise, run the risk of being charged, along with their client, when a Ponzi scheme collapses, or is discovered. As we have seen demonstrated repeatedly, all the players in a Ponzi scheme generally are targeted by law enforcement, and face justice, when it is exposed, or implodes, for lack of funds. Even participants who are on the fringe of the scheme are often charged with the entire weight of the scheme. Your proof: Livoti also was hit with $826m in Restitution. Lawyers for Ponzi schemes fall when their clients fall. 

LADIES, WHEN DOING BUSINESS IN PANAMA, AVOID THIS PREDATOR

Readers of this blog have learned that, in Panama, the American businessman Gary James Lundgren has a long and sordid history of perpetrating fraud and forgery upon unsuspecting foreigners, which has made him a wealthy man, but the additional dangers that he presents to female investors are more physical than they are financial. Lundgren is a dangerous sexual predator, ladies, and you are well advised that, if you must meet with him, kindly bring along a strong male friend, to run interference for you, and protect you.

Lundgren, who has a history of sexual harassment. and inappropriate physical contact in the United States, which resulted in a substantial fine, as well as attorneys' fees, in the State of Washington*, is believed to have relocated to the Republic of Panama, fleeing additional sexual charges. Arriving without any assets, his contact with darker elements of the Colombian underground "economy" soon resulted in his immediate affluence, and he has acquired a reputation as a money launderer, verified by eyewitnesses in Panama.

There is a long list of single, and unescorted females in Panama who have accused Lundgren of everything from fondling them, to rape, but the Panamanian police, who rarely arrest sexual battery offenders without eyewitness verification of the crime, have turned away his victims for years. Also, his sleazy Panama City attorney, Alcides Bartolo Peña Villar*, has bribed many a judge and prosecutor for his client, to ensure that Lundgren will escape responsibility for any criminal charges that are reported to the authorities, and to dismiss any that are reported.

In one case Lundgren repeatedly attempted to attack a lone businesswoman, who was seeking a loan, and if not for the intervention of others, he would certainly have committed sexual battery upon her. When he did not get his way, he charged her an interest rate in excess of twenty per cent. He also repeatedly delayed granting loan, while he persisted in his unwanted advances, some of which were abrupt and physical; there is no romance involved.

Other victims have reportedly been paid to ensure their silence, or afforded employment, through Lundgren's efforts, to prevent them from reporting him to law enforcement. Some of these women have been telling their stories to attorneys, and you can expect to see civil suits filed shortly.

You are advised to invest in securities or real estate, or to lease office or residential space, from other, more legitimate parties, as he is believed to be under criminal investigation in the United States, by multiple agencies. So long as he remains in Panama, steer clear of Gary Lundgren, or any of the companies that he controls, lest you become his next victim.
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*Fraudster in Panama has History as Sexual Predator
** Notwithstanding that he is a licensed attorney in the Republic of Panama, I cannot find a single picture of Peña in the society, professional or business print media, and he has a reputation of refusing to allow his picture to be taken at a social or public event.  

NORTH AMERICAN & EUROPEAN INVESTIGATORS HAVE BEEN IN PANAMA ALL WEEK

Investigators, from the United States, Canada and the European Union (EU), have been working in the Republic of Panama all week, regarding unspecified securities matter. It is not know whether they are from regulatory authorities (e.g. SEC, OSC, FINRA, or ESMA), or if they are from law enforcement agencies in those countries. Three individuals from the US, two from Canada, and one from the EU have been seen in Panama City.

Informed sources in Panama City advise that the Government of Panama is not releasing any information concerning these investigation, though it has been rumored that official Panamanian cooperation has been less than satisfactory, especially regarding the timely availability of documents for examination by the investigators. Whether they are investigating the Financial Pacific/Petaquilla mining Ltd. scandal is not known at this time. Panamanian media has thus far declined to cover the story; whether anyone in the government has pressured media to ignore it is not known.

Many Panamanians are painfully aware that the SMV*, the country's securities regulator, has not been the subject of any reform efforts, notwithstanding the global adverse publicity surrounding the Financial Pacific scandal, and the abrupt termination of all in-house investigations of the case, by senior SMV officials, all of whom are now under criminal investigation. SMV is broken, and the Republic of Panama has taken no steps to fix it, or disband it, and to form a new agency to regulate securities. Frankly, the new administration has had a year to clean house at SMV, but nothing has been done; It is high time to shut it down.
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* Loose English translation: Superintendency of the Securities Market. 

CENTRAL ROLE OF FINANCIAL PACIFIC IN MASSIVE CORRUPTION IN PANAMA DETAILED

Investigators looking into several areas where portions of Panamanian government funds, earmarked for major projects, were siphoned off, for the benefits of several of the country's senior PEPs, including members of the judiciary, have learned that Financial Pacific, heretofore the operator the Petaquilla Mining insider trading scam, was also deeply involved in other illegal acts.

This diagram, which was created by La Estrella, one of Panama's leading newspapers*, and based upon information made available, confirms the central role played by Financial Pacific, in the payment of millions of dollars in illegal kickbacks to Panamanian PEPs, by the Ecuadorian contractor, Hidalgo & Hidalgo SA. If every major government project involved bribes & kickbacks, it will take several years to unravel all the details, and it is believed that even those government officials currently holding office,  and who have ostensibly embarked upon a reform crusade, will also be implicated, all the way up to the country's sitting president. Many fear that only the most visible offenders will be exposed, and charged, and that the underlying systemic corruption will survive.

For those who have an interest, the Petaquilla case continues to develop outside of Panama. A large number of unlicensed securities dealers, bloggers, Panamanian businessmen, and others who were privy to the inside information on Petaquilla Mine, took illegal advantage of that knowledge, to the detriment of innocent investors, who flocked to purchase the stock. US, Canadian and EU securities regulators are investigating the case, as many of their nationals lost millions in the scam.

Country Risk, due to the totality of the corruption being exposed, will be seriously affected. Whether the widespread scandals will drive off critical foreign investment cannot be determined at this time, but if that is the net result, then Panama's attraction as an offshore financial center could decline, as the safety and viability of invested capital will be questioned. That will leave only those investors with dirty money moving into the economy, and that is disturbing, for Panama's efforts to be removed from the "Grey List" of uncooperative jurisdictions will fail.
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* Adelita Coriat, one of La Estrella's investigative reporters, has covered many of the scandals in depth. If you require additional details, it is suggested that you review her recent articles.

FRAUDSTER IN PANAMA HAS HISTORY AS SEXUAL PREDATOR

     

Lundgren and friends

Gary James Lundgren, the powerful American fraudster operating in Panama, whom we have been covering of late, also has a long history as a sexual predator. In a Court of Appeals of Washington decision*, we learn that Lundgren, as well as his companies, InterPacific Investment Services, inc., and Global Finance & Investment Company. A female victim was awarded a judgment for damages for $43,500, plus $257,751 in attorneys' fees, for hostile environment sexual harassment. He appealed the decision.

The Court of Appeals affirmed, holding that the trial court did not abuse its discretion. One wonder whether any of those investors who signed on with Lundgren's companies saw that information before committing funds.

That was in the United States; since relocating to Panama, Lundgren has been accused of;

(1) Demanding sex from female clients, as a precondition to extending them a loan.
(2) Committing sexual battery on his employees, and then paying them a large sum to not report him to the authorities. In essence, a cover-up. One employee resigned, rather than endure his unwelcome physical advances.
(3) Attempting to rape single females that he comes into contact with in business.
(4) Delaying financial transactions, all the while making unwanted sexual overtures to businesswomen that he is working with.

Why is he not in prison, as a sex offender ? Panama's macho environment generally makes sexual battery cases impossible to prosecute, and remember, Mr. Lundgren has the famous "fixer" as his attorney, Alcides Bartolo Peña, and he is well know for his ability to manipulate the court system, through the extensive use of bribes and favors.

As we have previously reported on this blog, if any of Gary Lundgren's investors had bothered to conduct even a rudimentary due diligence investigation, they would have exposed many skeletons in his financial closet, and these sexual crimes merely add to a long list of sins and transgressions that disqualifies him from any serious consideration as a broker or investment counselor, neither of which he holds a Panama license for.
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*Steele vs. Lundgren, 982 P.2d 617 (Wash. Ct. App. 1999) readers who do not have access can review the complete text of the decision here.

Note about photograph: Lundgren, with his known associates;  Panama's fugitive ex-President Ricardo Martinelli, and convicted Colombian Ponzi schemer, David Eduardo Helmut Murcia Guzmán.

ALERT ON HAMAS-LINKED NGO RECOGNIZED BY UNITED NATIONS AGENCY

A division of the United Nations, the UN ECOSOC, has been granted consultative status to the Palestinian Return Centre (PRC), a UK-based* NGO whose senior officers have direct links to organizations that fund Hamas, a Specially Designated Global Terrorist (SDGT) Organization. The PRC, which supports Palestinian terrorist actions against Israel, and discourages a negotiated diplomatic solution, operates upon the flawed premise that there exists some sort of legal right of return to Israel, for Palestinians.

If you remember what you were taught in history class, you know that the Arab countries invading Israel in 1948 instructed Arab residents to leave the country, to facilitate their military actions. After Israel defeated the invaders, the 700,000 Arabs who had left voluntarily were placed into refugee camps, around the Middle East, rather than integrated as immigrants. Their descendants remain there today, largely banned from full participation in the economic life of those countries, such as Lebanon and Syria, where they remain, largely stateless and abandoned by the nations who told them they would return to  an Arab Palestine after the defeat of Israel.

On the other hand, the 900,000 Jewish residents of the Middle East, who were abruptly expelled in the aftermath of the 1948 war, have all been absorbed in Israel, but the Arabs who left, and whose leaders designated themselves as Palestinians in 1964, have never been absorbed in the countries where they immigrated to.  The demands for the so-called right of return has been one of the largest stumbling blocks to a negotiated solution between Israel and the PLO, although refugees displaced by war have historically been assimilated into the receiving countries.

Compliance officers should be mindful of the direct Hamas links to the PRC, and banking this organization, or facilitating any funds transfers, or funding in any form, could constitute violations of OFAC sanctions, as well as the sanctions in place in several other countries.

Hamas leadership congratulating PRC for UN recognition

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* Address: 1H Crown House, 60 N Circular Road, London NW10 7PM, UK (+44 20 8453 0919)

CORRUPTION WITHOUT LIMITS DURING MARTINELLI ADMINISTRATION

Look at the above table, constructed by one of Panama's leading investigative reporters; it details millions of dollars in kickbacks, paid out to corrupt Panamanian PEPs, in only one construction contract initiated during Ricardo Martinelli's administration. Gabriel Btesh and Felipe Virsi, two of Martinelli's closest associates, received huge sums, and I stress that this is but one matter. The kickbacks, which reportedly came from an Ecuadorian contractor, Hidalgo & Hidalgo, and appears to come to $5.2m, out of a $37.2m project.

Literally, billions of dollars was diverted, embezzled, stolen outright, and taken, from the assets of the Republic of Panama, during Martinelli's corrupt reign. The extent of the rampant corruption may never be known, but the anti-corruption prosecutors in Panama are continuing to expose its depth and breadth.

A WORD TO THE WISE ON US REMOVAL OF CUBA FROM LIST OF STATE SPONSORS OF TERRORISM

According to this week's news, US Secretary of State has removed the Republic of Cuba from the list of State Sponsors of Terrorism, as the 45-day period for Congressional objections having expired, and no action was taken. That being said, compliance officers should stress to their bank customers that this is a removal of Cuba from the terrorist facilitators list, not a deletion of the terrorist organizations from OFAC and other sanctions lists.

Cuba may have persuaded State that it no longer promotes terrorist organizations, but it has not expelled their members from Havana, nor has it closed their offices. Be alert, and thoroughly check any and all individuals who are inside Cuba, when it comes to your bank clients' moves to conduct or establish businesses inside Cuba. You do not want any FARC, ELN or ETA agents as your clients' business partners, local representatives, or agents in Cuba. You also need to be aware that Hezbollah, Hamas and several other smaller Palestinian terrorist groups, all have relationships with Cuba, and have agents resident there, and they communicate with their other cells, in Venezuela, where they are raising money through drug trafficking. Disregard Cuba's statements about how it no longer supports these terrorist organizations; those groups are still operating in Cuba.

WHY DID GLOBAL BANKS MOVE $150m IN FIFA BRIBE MONEY ?

"For the good of the game."

If you have not yet read the complete text of the 166-page indictment in United States vs. Jeffrey Webb, et al* the FIFA case, in which many senior FIFA officials, and others, are charges in a massive indictment, with multiple counts of RICO, money laundering and wire fraud involving $150m, you do not know that only one bank, of the more than twenty specifically identified in the charges, refused to complete wire transfers of large sums for the defendants. There are others, located in Switzerland, New York, and Paraguay, to list a few, but all of these banks failed to inquire into the circumstances of the transactions, negligent acts that I call  compliance malpractice.

Senior officials of any NGO, non-profit, or similar entity, are considered to be Politically Exposed persons, or PEPs, as are individuals closely connected to them, but it appears that bank customers who were FIFA officials, or officers in other related sports entities, were given a free pass to move huge amounts of money, without question.

The banks listed in the indictment, from my review of the document, are:

Capital Bank (Panama)
Citi Private Bank
Delta National Bank & Trust Co. (Miami)
Banco do Brasil
First Citizens Bank (Trinidad & Tobago)
Barclays Bank (Cayman Islands)
Bank Itaú (New York City)
Bank of America
Republic Bank (Trinidad & Tobago)
First Caribbean International Bank (Bahamas)
Delta Bank (Qatar)
Intercommercial Bank (Trinidad & Tobago)
HSBC Bank (Hong Kong)
Standard Chartered Bank (New York City)
Fidelity Bank (Cayman Islands)
SunTrust Bank (Georgia)
JP Morgan Chase Bank (NYC and Miami)
Espirito Santo Bank (Miami)
Wells Fargo Bank (NYC)
Bank Hapoalim (Zurich)
Bank Julius Baer (Zurich)

None of the above banks have been charged with any crime, or regulatory violation, but one must assume that they are under the microscope somewhere, due to their role in the FIFA case. One wonders: didn't their compliance departments wonder what all these large wire transfers were for ?

Readers who wish to review the complete text of the indictment can access it here. The document is searchable, through a feature appearing on the webpage.

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* Case No.: 15-CR-0252-RSD-RML (EDNY).

FRAUDSTER OPERATING IN PANAMA HAD PREVIOUSLY POLLUTED AMERICAN WATERWAYS

Investors who placed orders for securities, or purchased real estate, through Alaskan native Gary James Lundgren in Panama, did not know that he had a dark past in the United States, which they would have easily found in any due diligence investigation. Lundgren is engaged in the sale of securities from his offices in Panama, although neither he, nor any of his corporate entities, is licensed by Panama's SMV to engage in securities brokerage, a violation of Panama's securities laws.

The  pollution case, which is styled "State of Washington, Department of Ecology vs. Gary Lundgren and Ketron Island Enterprises, Inc*.," involved Lundgren's sole ownership of a corporation (sewage treatment plant) that illegally discharged raw sewage into Puget Sound. The State agency found that his promises to remedy the pollution were not made in good faith, and ordered him to dismantle the facility, which he failed to do.

 He appealed an administrative ruling, and a $250,000 fine, to first the Superior Court, which found him personally liable, and finally to the Court of Appeals of Washington, that state's highest court. The Court of Appeals affirmed that Lundgren was personally liable, pursuant to the Responsible Owner Doctrine, which holds that a corporate officer can be held criminally liable, where the officer stands "in responsible relation to a public danger."

Lundgren conveyed the land containing the sewage plant, to a corporation, which agreed to assume liability for the fine, but Washington records, and reliable sources, show that Lundgren owns that entity as well;  he was merely seeking to shift financial responsibility to a third party. through a bogus "sale."

Had any of the American and Canadian expats, who have been defrauded by Gary Lundgren in Panama, through his theft of bearer shares representing ownership of Panamanian corporations that owned real estate of the victims, simply conducted a due diligence investigation**, they would have been warned not to do business with this fraudster, whose Panama City lawyer, Alcides Bartolo Peña, has made a career out delaying justice for years, when the victims seek legal redress for their injuries. This demonstrates how critical due diligence is, prior to engaging in any business transaction, whether commercial or personal.

Mr. Lundgren, who is now refusing to come to the front door of his Panama office, and speak with any of his victims, would have been identified to them, as a major problem, early on, if they had done their homework.
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* The decision can be accessed here. Readers who are attorneys, and have access to either the official or unofficial decisions of Washington, may find them here:    State Department of Ecology v. Lundgren, 94 Wn.App. 236, 971 P.2d 948 .
** Additionally, a due diligence search will also uncover a reported sexual harassment decision that establishes Gary James Lundgren as a sexual predator; we shall  cover this topic in a future article, but that information alone makes Lundgren an unacceptable risk for any business transaction. it is publicly available on the Internet.

DID BANKS WHERE HASTERT HAD ACCOUNTS DROP THE BALL ?

The Federal indictment of former Speaker of the US House of Representatives, J Dennis Hastert, on charges of Structuring to Avoid Reporting Requirements, and lying to Federal law enforcement agents, reminds us that the bank accounts of politicians, even former or retired ones, deserve special attention from compliance. Here, Hastert was engaged in paying off an individual against whom he had committed some unspecified misconduct, probably while a high school teacher or coach, but the payments could very well have involved criminal activities.

Hastert's conduct, which occurred after he had left the House of Representatives, for a lucrative new career as a lobbyist, was discovered after the FBI & IRS investigated the possibility that he was the target of a criminal extortion plot. Apparently, he was paying the money, said to be a total of $3.5m, on a voluntary basis, but we do not know what the details are at this point.

The real crime here:

(1) Hastert withdrew $50,000, fifteen times, from his US bank accounts, over two years, before his bankers raised any questions about the circumstances of the withdrawals. This sounds like compliance malpractice, in my book.

(2) Then, in response to their inquiries, he structured his future, regular withdrawals, so that each one would be under the $10,000 threshold for reporting. However, his bankers still let this happen for an additional two years, before a criminal investigation was initiated. What happened here, I wonder ?

One wonders whether there was a special relationship between Hastert, and his bankers, that interfered with the filing of CTRs, or with immediate notification of his actions to bank counsel for investigation, and also to law enforcement. Prominent former politicians often are coveted by bankers, not just for their business, but for the potential referral of lucrative business of their lobbying clientele. Did customer relationship managers trump compliance concerns here ?

The banks named in the indictment are:
(A) Old Second Bank
(B) People's State Bank
(C) Castle Bank
(D) Chase Bank

To be fair, we do not know whether Hastert alternated his cash withdrawals among these banks, as those details are not specified in the Indictment, not whether any CTRs were timely filed. Unfortunately, should he enter a guilty plea, we may never know these important details, but we hope that compliance officers at financial institutions whose clients include present or former politicians govern themselves accordingly, lest they also find their banks' compliance shortcomings exposed in a public forum, with probable reputation damage as the result.

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* Research note: The Indictment is not yet publicly available on the government website, Public Access to Court Electronic Documents, but it is on the site of the US Attorney's Office for the Northern District of Illinois, should any reader need to access it. The case number does not appear on that image.